Taxation of international shipping and air transport: profits from international operations taxable only in the enterprise's state of residence. Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; if a shipping enterprise's effective management is aboard a ship, it is deemed located in the State of the ship's home harbor or the operator's State of residence. Profits from use, maintenance or rental of containers for international traffic are taxable only in the resident State unless used solely within the other Contracting State; the exclusive taxation rule also covers participation in pools, joint businesses or international operating agencies.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of international shipping and air transport: profits from international operations taxable only in the enterprise's state of residence.
Profits from operating ships or aircraft in international traffic are taxable only in the enterprise's State of residence; if a shipping enterprise's effective management is aboard a ship, it is deemed located in the State of the ship's home harbor or the operator's State of residence. Profits from use, maintenance or rental of containers for international traffic are taxable only in the resident State unless used solely within the other Contracting State; the exclusive taxation rule also covers participation in pools, joint businesses or international operating agencies.
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